Privacy Policy data privacy data protection Valletta

Effective on and from: 17 August 2025

At Noetic Ltd. ("we", "our", "us"), we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

Noetic Ltd. is the Data Controller in respect of the personal data we collect.

1. What Personal Data We Collect

We collect and process the following categories of personal data:

• Name
• Email address
• Phone number
• Job title or department
• Company you work for
• Any other information you voluntarily provide through contact forms, email, or our services.

Please be aware that the vast majority of data we process is not personal data. Our clients are primarily other businesses, however, in the course of dealing with business clients, we will need to process personal data, for example, the personal data of the individual / contact we are dealing with at the client company. 

2. Why We Process Your Personal Data

We process your personal data for the following purposes:

• To register you as a client
• To provide GDPR and AI compliance services
• To manage our relationship with you (e.g. updates, billing, service communications)
• To comply with our legal obligations
• To send monthly newsletters if you have confirmed you would like to receive these. 

3. Legal Basis for Processing

We process your data based on one or more of the following legal grounds:

• Performance of a contract eg to provide you with a Contract for Services 
• Compliance with legal obligations 
• Consent – we only carry out direct marketing where the recipient has provided explicit  consent. We do not carry out direct marketing on the basis of legitimate interests.      

4. Who We Share Your Data With

We do not sell your personal data. We may share it with competent authorities (eg Data Protection Authorities, Malta Digital Innovation Authority or other Market Surveillance Authorities), only:

• With your consent, or
• Where required by applicable law or regulation.

5. Data Transfers Outside the EEA

• For EU-based clients, we do not transfer personal data outside the European Economic Area (EEA).
• For non-EEA clients, we may transfer data internationally. However, if transfer of data outside the EEA is required and the recipient jurisdiction is not whitelisted by the EU Commission, then we will take appropriate safeguards to protect personal data, such as using Standard Contractual Clauses.

6. Data Retention

We retain personal data for as long as necessary to provide our services and fulfill legal and contractual obligations. Specifically, we retain personal data:

• For the duration of your engagement with us, and
• For up to 6 years thereafter, for legal and compliance purposes

7. Your Rights Under the GDPR

You have the following rights:

• Right to access - Request a copy of your personal data
• Right to rectification - Request corrections to inaccurate or incomplete data
• Right to erasure - Ask us to delete your personal data (under certain conditions)
• Right to restrict processing - Limit how we use your data
• Right to data portability - Request transfer of your data to another provider
• Right to lodge a complaint - with your local supervisory authority, for example, in Malta this is the Office of the Information and Data Protection Commissioner (IDPC). They can be contacted by telephone: +356 2328 7100 or email: idpc.info@idpc.org.mt
• Right to object - Object to our processing based on legitimate interests
  • However, please note that we do not process any personal data on the basis of legitimate interests.

To exercise your rights, contact us at: info@noetic.global

8. Automated Decision-Making

We do not use your personal data to carry out any automated decision-making or profiling that produces legal or similarly significant effects.

9. Contact Details

If you have any questions about this policy or how we handle your data, please email: info@noetic.global

10. Changes to this Policy

We may update this Privacy Policy from time to time. Please check back periodically. Any significant changes will be notified on our website.